Posted inInternal Controls

SEC May Delay 404 For Some Companies

The Securities and Exchange Commission may postpone the implementation of Section 404 of the Sarbanes-Oxley Act for certain companies. Nicolaisen Donald Nicolaisen, the Commission’s chief accountant, confirmed the regulator is considering a delay, possibly for smaller companies that are having difficulty meeting the deadline, which is currently for all filers above $75 million in market […]

Posted inInternal Controls

Largest Accounting Firms Issue Joint 404 Framework

Last week, nine accounting firmsโ€”including eight of the largest in the countryโ€”issued a joint framework for use in implementing Section 404 of The Sarbanes-Oxley Act. This paper, released Oct. 28, outlines a “suggested framework for evaluating manual and automated process/transaction-level exceptions and deficiencies” resulting from the evaluation of a companyโ€™s internal control over financial reporting. […]

Posted inInternal Controls

Companies Migrating From SOX ‘Myopia’ To ERM

Howโ€™s this for an understatement: โ€œThere has developed what seems to be an overemphasis on certain additional or duplicative levels of documentation, with a declining value in terms of how much that additional documentation would add to the effectiveness of internal control.โ€ Thatโ€™s according to Arnie Hanish, the chief accounting officer of Eli Lilly and […]

Posted inInternal Controls

Electronic Records Retention: Getting It Right

The computer’s common use as an essential business tool, and the tremendous and exponentially increasing storage capacity of computer generated or recorded information has transformed the landscape of information retention and destruction. Now record retention regulations are becoming increasingly important to follow, and follow correctly and consistently. Certain regulations in particular illustrate this need, including […]

Posted inInternal Controls

Q&A With Kaiser Permanente’s Compliance Officer

This profile is the latest in a series of weekly conversations with executives at U.S. public companies who are currently involved in establishing and developing compliance programs. An index of previous conversations is available here. Weโ€™ve never interviewed the compliance officer of a nonprofit before. What do you oversee? Well, Kaiser is a complicated institution. […]

Posted inInternal Controls

Internal Control Disclosures From September

SECTION 404 The September Data View The Actual Internal Control Disclosures From September View Sample Disclosures Of Remediation Efforts From September View Samples Of Internal Controls As Risk Factors According to a review of regulatory filings, 40 companies disclosed material weaknesses or significant deficiencies in internal controls during the month of September, and dozens of […]

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